Satisfactory Academic
Progress
The Regulations
and
Implementation at Berkeley College
Howard Leslie – Vice President, Financial
Bryan Hoppe – SAP Coordinator
Satisfactory Academic
Progress
• Schools must have reasonable standards for measuring a
student’s satisfactory academic progress toward the degree or
certificate
 A reasonable standard is in accordance with updated
(PROGRAM INTEGRITY 2010 – EFFECTIVE 2011)
regulatory section 668.34
 Consistent application to all students within categories of
students
 Monitored at least annually
 Description of effects of course incompletes, withdrawals,
repeated courses and transfer in credits
 Have a stated Maximum time frame
SAP Policy Must Include
 Specific GPA requirement (Qualitative)
 Pace requirement (Quantitative)
 Treatment of transfer credits
 Treatment for Remedial and ESL
 Financial aid warning definition*
 Financial aid probation definition*
 Academic Plan definition*
 Appeal Process
*Must schools adopt the terminology, such as warning
and probation, used in the regulations?
Yes. The preamble to the October 29, 2011 final
regulations (75 FR 66884) states that institutions must
incorporate these regulatory changes into the information
they provide to students; this includes ensuring that the
information made available by the institution uses the
terminology used in the regulations. Therefore, to the
extent that your institution uses the statuses we describe
in the new regulations, it must use the terminology in the
regulations.
How Often is SAP Evaluated?
Options:
 For programs of study that are one academic year or
less in length, school must evaluate SAP at end of
each payment period.
 For programs of study longer than one academic year
School must evaluate at least annually to correspond
with end of a payment period but a School may
evaluate at end of each payment period.
 If annual option is selected there is a sacrifice – stay
tuned.
SAP Evaluations
 Each official evaluation must include evaluation of
GPA and pace
 Evaluations must be at end of payment period no
matter how often progress is monitored
 Clock hour schools – see Electronic Announcement
June 6, 2011
http://www.ifap.ed.gov/eannouncements/
060611SAPReviewforStudentsinClockHrs.html
SAP Policy Requirements
(continued)
SAP policy must describe how
student’s GPA and pace of
completion are affected by:
Incompletes
Withdrawals
Repetitions
School’s policy for Transfer of credit
from other institutions (Accepted
transfer credits count as both
attempted and completed hours )
GPA Requirement
 Specify GPA required at each evaluation
point
 If GPA not appropriate, standard must be a
comparable assessment measured against a
norm
 For programs longer than two academic
years, “C” average or equivalent required at
end of second year, or academic standing
consistent with the institution’s requirements
for graduation
 Key consideration: Will GPA be at graduation
requirement before student reaches Max
Time-frame?
Pace Requirement
 Quantitative component:
 Policy specifies the pace at which a student
must complete in order to complete within
maximum time to complete
 School must evaluate Cumulative hours
completed and
Cumulative hours attempted
 Schools are to make public the length of their
programs
(Part of Consumer disclosures)
Maximum Time Frame
 For undergraduate programs, must be no longer than
150% of published length of educational program
 For credit hour programs, as measured in credit hours
attempted
 For clock hour programs, as measured in cumulative
clock hours required to complete and expressed in
calendar time
 For gradate programs of study, school defines the
maximum based upon length of program
Credit Hour Example
BA requires 120 credits for graduation
Maximum Time Frame = 150% X 120 = 180 credits
Pace calculation :
120/180 = 67% (also 100/150 = 67%)
Student earning 67% of credits attempted is on pace to
complete the program within the maximum time frame.
Applicable at any enrollment status
Clock Hour Example
Program is 1,200 clock hours
Students attend 30 hours per week
Program scheduled to last 40 weeks
40 X 150% = 60 weeks maximum time frame
A student must complete 20 hours per week in order
to complete 1,200 hours in 60 weeks
Financial Aid Warning
 Status only available to students at
schools that monitor progress at the
end of each payment period
 Student may receive Title IV aid for
one additional payment period
 Status may be assigned without
student action or appeal
 Status is optional
After Financial Aid Warning
 Student meets SAP standards and is off
warning
 Student does not meet SAP standards:
 Student successfully appeals and is
placed on probation or an academic plan
or
 Student does not appeal, or appeal is
denied and school explains how student
can regain eligibility
Annual Evaluations
 Financial Aid Warning status not
available
 Probation requirements same as
schools that evaluate at each
payment period
 Student not making progress is not
eligible for further Title IV assistance,
unless student successfully appeals
SAP Appeal
 Process by which a student who is not
meeting SAP standards appeals for
reconsideration of eligibility for Title IV aid
Policy must describe conditions under which
a student may file an appeal
 Appeal must include information from
student explaining why the student failed to
make SAP and what has changed that will
allow the student to make SAP at next
evaluation point
 Appeal process is optional
SAP Appeal Approval
School determines that student will be
able to make SAP standards by end of
next payment period
OR
Student is placed on an academic plan
that will ensure the student is able to
meet SAP standards by a specific point
in time
Financial Aid Probation
 Status available for a student not
making progress who has appealed
and had aid eligibility reinstated
 Student may receive aid for one
additional payment period
 School may require student action
while on probation
 Possible use of academic plan
After Financial Aid Probation
 Student meets SAP standards and
regains aid eligibility
 Student does not meet standards :
 Student successfully appeals and is
placed on an academic plan
Or
 Student does not appeal, or appeal is
denied and school explains how
student can regain eligibility
Academic Plan
 Alternative to probation – available to all
schools
 A plan that, if followed by the student,
specifies a point in time at which the student
will be able to meet the institution’s SAP
standards
 Student on plan is evaluated against the plan
requirements, not regular SAP standards
 Plan should ensure student completes within
maximum timeframe of program or have
procedures of how
this will be evaluated and time extended
SAP Notifications
 Institution must notify student of results of
SAP review that impacts the student’s
eligibility for Title IV aid
 If institution has appeal process, must
describe the specific elements required to
appeal SAP
 May specify how often and how many
appeals are allowed
 If no appeal process, description of how
student may re-establish eligibility for
future Title IV aid must be specified
Ask Yourself
Do you have fixed or graduated standards?
How will you treat course incompletes, withdrawals and
repetitions?
How will you treat transfer credits?
How will you treat remedial courses?
How will you treat changes of major or program? Will these be
limited?
Will your policy permit appeals? If so, how many?
Who will review appeals?
Will your policy permit academic plans?
Who will develop academic plans? Approve? Monitor?
Very Important: Do you have your SAP policies published and
Satisfactory Progress
Definitions
Appeal—A process by which a student who is not meeting
SAP standards petitions the school for reconsideration of
his eligibility for FSA funds. Optional process. conditions
may include a academic plan for success.
Financial aid probation—A status a school assigns to a
student who is failing to make satisfactory academic
progress and who successfully appeals. Eligibility for aid
may be reinstated for one payment period.
Satisfactory Progress
Definitions
Financial aid warning—A status a school assigns to a
student who is failing to make satisfactory academic
progress. The school reinstates eligibility for aid for
one payment period and may do so without a student
appeal. This status may only be used by schools that
check SAP at the end of each payment period and
only for students who were making SAP in the prior
payment period.
Financial aid suspension – student failed to meet
minimum standard and
was on a FA warning status and/or reached maximum
time frame
for Program of Study
Satisfactory Progress Definitions
Maximum timeframe—
• For an undergraduate program measured in credit hours, a
period no longer than 150 percent of the published length of
the program.
• For an undergraduate program measured in clock hours, a
period no longer than 150 percent of the published length of
the program as measured by the cumulative number of clock
hours the student is required to complete and expressed in
calendar time. (Note that a student in a clock hour program
cannot receive aid for hours beyond those in the program; the
maximum timeframe applies to the amount of calendar time the
student takes to complete those hours.)
• For a graduate program, a period the school defines as time
limit
IMPLEMENTATION
AT BERKELEY COLLEGE
Basics
• Collaboration with Academic Advisement
• SAP Policy and Academic Policy are equivalent to ensure
consistent message to students
• Although some individual programs have stronger standards such as
minimum grade requirements
• Reviewed after every Term
• Not approached as punitive, rather as an effective tool to identify
at-risk students
• Focused on providing resources to improve struggling students
Qualitative SAP Standards.
Undergraduate Programs
Associates Degrees
Bachelors Degrees
Attempted
Credits
Required
GPA
Attempted
Credits
Required
GPA
0-15
1.50
0-30
1.60
16-30
1.60
31-60
1.75
31-44
1.75
61-75
1.80
45 or more
2.00
76-89
1.90
90 or
more
2.00
Certificate Programs
Required GPA
2.00
Quantitative SAP Standards
Undergraduate Programs
Degree Programs
Certificate Programs
Attempted Credits
Necessary %
Passed
Attempted
Credits
Necessary %
Passed
0-16
25
0-24
50
17-32
37
25-36
60
33-48
50
37 or more
67
49-64
56
65-80
65
81 or more
67
Flow of SAP Statuses
Fall
below WARN
standa
rd
MEE
T
MEE
T
Academi
c Plan
Probatio
n
Appeal
MEE
T
Appeal
NET4
NET
4
NET4
Graduate Program SAP Standards
Quantitative Standard
Attempted Credits
Necessary %
Passed
0-12
50%
13-27
65%
28 or more
67%
Qualitative Standard
Attempted
Credits
Required GPA
0-11
2.6
12 or more
3.0
Why Academic Advisement?
• Academic Advisors handle the discussions with students
on academic progress instead of Financial Aid staff.
• This ensures that students that are most in need of
advisement receive it.
• A well designed PeopleSoft system ensures that both
Financial Aid and Academic Advisement have all of the
resources they need to properly hold students to
standards while helping them overcome obstacles to their
success.
Focus on Providing Assistance
• Instead of relying on the threat of loss of funding as a
motivator, Advisors aim to identify the source of the
student’s struggles and offer resources to overcome them,
such as:
• Tutoring through the Academic Support Center
• Counseling Services
• Scheduling issues and Academic Load considerations
• Discussions of Academic Programs and finding the “right fit”
• Each student faces different challenges, and identifying
these are in both the student and organization’s best
interests
Advisor input regarding appeals
• SAP appeals are reviewed by a committee ensuring
consistency across all 10 campuses, but input from
advisors is included
• Student’s appeals are reviewed by their advisor before
being sent to committee
• As the direct student contact Advisors often provide insight into the
student’s situation much deeper than the committee would have
otherwise
• Decisions are NOT made by advisors, but their
recommendations and comments are included for
committee review along with the student’s appeal
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2
3
4
• Student files an appeal
• Advisor at local campus adds recommendation
• Appeal is sent to central committee for review
• Decision on appeal is reached, student is informed
and appropriate indicators are issued in PeopleSoft
Service Indicators Force Discussion
• Holds placed on students’ accounts prevent them from
scheduling themselves for courses, which forces a
conversation with Academic Advisement.
• Guarantees that every SAP student is given the
opportunity to fully understand their status
• Person-to-person is much more effective than the required letters
alone.
• Graduated standards means that as attempted credits increase the
standards increase as well, so students need to understand not
only what standard they fell below but also the standard they will be
held to following their next quarter
• Students on Warning are often the population with the
greatest impact potential
Warning students as the front line
• Checking SAP after each payment period allows the use
of a Warning status, which we have found is a very helpful
step
• Students are able to continue into a Warning quarter
without appealing, but are forced by an indicator to speak
with advisement before creating any future schedules
• Students on Warning are often the easiest to resolve
because they’ve only fallen below standards a single
quarter
• Mathematically they are the easiest to resolve, so if the issues
contributing to poor performance can be dealt with early they have
great potential to improve quickly
Following Warning quarter
• Students that improve and are meeting SAP
• Those still below standards must appeal (and placed on
Probation if approved)
• Some worsened their situation, should be dismissed
• Some stayed stagnant, would need compelling explanation to be
allowed to continue
• Advisor’s perspective is helpful to consider for cases on the fence
• Some improved, but not by enough to be above standard
Academic Plans
• Students still below SAP following their Probation quarter
must appeal again
• Dismissed when appropriate
• Placed on Academic Plan if approved
• Academic Plans can be for multiple quarters, but always
set specific benchmarks for the student to reach at the
end of the quarter
• Academic Plan students are reviewed at the end of each quarter,
students that violated the terms of their plan are dismissed
Academic Plans, cont.
• Students that are approved to continue on Plan meet
again with Advisor to update plan with specifics based on
recent performance.
• Academic plans can include multiple quarters, but always
have specifics expectations for the quarter at hand
Dismissals
• Dismissed students MUST sit out at least 1 Quarter
• Dismissed students wishing to return must file an appeal
• Such appeals need to be compelling
• If approved, dismissed students are always treated as if this was
their second appeal and placed on Academic Plan
Readmitting Students
• Students that last attended prior to the current SAP
standards (adopted in 2012) are held to the highest SAP
standard upon reentry (2.0 GPA and 67% E/A)
• Students below these metrics appeal to return regardless of where
their attempted credits would put them on the graduated SAP
standards
• Since the policy is designed to identify at-risk students and not be
punitive, this guarantees that students that do need SAP-like
attention are not overlooked
• After a quarter in class they are held to the normal SAP Standards
Standards Remain Consistent
• Providing compassionate assistance is not the same as
being lenient
• Students are provided resources to improve, but it is their
choice to accept the help and move forward
• Dismissals are not only appropriate in some cases, but
compassionate as well
SAP Compliance Concerns




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Failure to develop a policy that meets minimum Title IV
requirements
Misalignment of pace of progression and maximum
timeframe
Applying a different policy than the official written SAP
policy
Failure to properly monitor and/or document
satisfactory progress
Consistently in the top ten
program review findings
Policy Q & A - Different Policies
Q1: Is an institution required to use the same SAP
policy for all students?
A1: No, the policy must explain the qualitative
(grade-based) and quantitative (time-related)
standards the institution uses to check SAP;
however, an institution is permitted to establish
different SAP standards for different programs or
categories (e.g., full-time, part-time,
undergraduate, and graduate students) which
must be applied consistently to students in that
category or program.
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Policy Q & A – Non-Accepted Credits
Q2: SAP regulations require credit-hours accepted toward
student’s program count as both attempted and completed
when calculating pace for SAP. Can an institution’s policy
include non-accepted credits as attempted credits for
purposes of these calculations?
A2: Yes. The treatment of these credits would be up to the
institution. The SAP regulations do not address nonaccepted credits.
• May refer to transfer credits or credits earned in other academic
programs at your school
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Policy Q & A - Remedial
• Q3: How are remedial courses treated for SAP purposes?
• A3: The institution's SAP policy should describe how
remedial courses are treated. An institution may, but is not
required to, include remedial coursework in determining
pace. However, the school must evaluate remedial
coursework under the qualitative factor, though it does not
have to be part of the GPA. If not part of the GPA, the
school must have some other measurement process to
evaluate remedial coursework (passing courses, meeting
course requirements, etc.).
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Policy Q & A – Programs > 2 yrs
Q4: How does the qualitative portion of a SAP review relate to
the requirement for a student to have a GPA of at least 2.0,
or academic standing consistent with the institution’s
requirements for graduation?
A4: …the Higher Education Act requires a specific qualitative
review at the end of the student’s second academic year. In
this context, we have interpreted the “second academic
year” as the student being at the school for 4 semesters or 6
quarters, regardless of a student’s enrollment status. At that
point, the student must have a GPA of at least a 2.0 or its
equivalent or have academic standing consistent with the
institution’s graduation requirements.
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Policy Q & A – Academic Plans
Q5: What is the status of a student who has completed the
probationary payment period and who is continuing to
receive aid by meeting the requirements of the student’s
academic plan?
A5: A student who has been reinstated to eligibility under an
academic plan and is making progress under that plan is
considered to be an eligible student.
• May be evaluated at the same time as other TIV recipients or at more
frequent periods based on plan
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Policy Q & A – Academic Plans
Q6: Can the academic plan be the same for all students or
the same by student categories or must the plan be
created individually for each student?
A6: According to the regulations, the academic plan is
developed by the institution and the student individually. It
is possible that a general plan could be used for students
in a similar circumstance and then customized, as
needed, for each student’s particular circumstance.
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Policy Q & A – Academic Plans
Q7: Must the academic plan be mathematically set to
graduate student within 150% timeframe?
A7: The academic plan must be designed to ensure that the
student is able to meet the institution's satisfactory
academic progress standards by a specific point in
time. In some cases, this could mean that the maximum
timeframe would be extended based on the student's
approved appeal.
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Policy Q & A - Probation
Q8: How many times may a student be
placed on probation for failing to meet
SAP standards?
A8: A student may be placed on probation
for one payment period per appeal. It is
possible that a student could be placed
on probation more than once in his or
her academic career.
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Policy Q & A - Amnesty
Q9: May an institution’s SAP policy include automatic
“academic amnesty” in certain circumstances, such as,
after a student has not attended for a certain number of
payment periods or years?
A9: No. The regulations permit use of the automatic
financial aid warning status for institutions that review SAP
at each payment period. No other status may be granted
automatically. A successful appeal is needed to grant
financial aid probation status or to develop an academic
plan.
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Policy Guidance – Academic
Plans
• Q10: The regulations indicate that an academic plan must
be designed for a student to meet SAP by a specific point
in time. How do we define a future point in time?
• A10: Where applicable a date should be used. If a date
cannot be confirmed then a school should use some kind
of defined end-point – after the 3rd semester, anticipated
graduation date, etc. If the graduation point is after the
150% max timeframe, the graduation point should be
indicated in some format. It cannot simply be an openended process; needs to be a finite point.
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Policy Guidance – Regaining Eligibility
• Q11: What happens if a student is on an academic
plan and at the of the payment period they are not
meeting the plan requirements but are now meeting
the general SAP standards?
• A11: Once a student is meeting the general SAP
standards at a checkpoint, regardless of the plan,
they are now in good standing (main point of the
plan is to help the student meet the SAP standards).
A school may want to indicate in a plan that a
student can continue receiving TIV aid if they meet
the plan criteria or meet all general SAP standards.
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Policy Guidance – Pass/Fail
Courses
• Q12: Does a school have to factor in
Pass/Fail classes, that are part of the
student’s program of study, as part of the
school’s qualitative measure (GPA)?
• A12: No, the school does not have to factor in
those limited classes a student takes as
Pass/Fail into the GPA measurement as long
as the course is factored into the quantitative
measurement (pace of progression).
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Resources/References
• FSA Assessments, Student Eligibility section:
• http://ifap.ed.gov/qahome/qaassessments/studentelig.html
 668.16, 668.34 (SAP)
 2014-15 FSA Handbook Vol. 1, Chapter 1
 Electronic Announcement - September 2, 2011
 Policy Q & A Webpage on program integrity regulations
 http://www2.ed.gov/policy/highered/reg/hearulemaking/2009
/integrity-qa.html
 Upper right-hand side of IFAP
 Topic – “Satisfactory Academic Progress”
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